Code of Ethics

1. GENERAL POLICY STATEMENT

   It is the policy of the Bank that the Principal Executive Officer and Principal Financial Officer ("Principal Officers") will conduct business in accordance with the highest ethical standards in order to merit and maintain the complete confidence and trust of its customers, shareholders and the public in general. Principal Officers must conduct their personal affairs and manage their business transactions in a manner that does not result in adverse comments or criticism from the public or in any way damage the Bank's reputation as a responsible financial services organization. This policy addresses the requirements for conflicts of interest, full, fair and accurate disclosure of reports, compliance with applicable laws, an internal procedure for prompt reporting of violations to this code, and accountability for adherence to the code.

   This Code of Ethics for Principal Officers is intended to supplement the requirements in the Bank's Code of Conduct that is applicable to all Bank officers and employees.

2. CODE OF ETHICS
   1. Conflicts of Interest. It is the policy of the Bank that all Principal Officers act in an honest and ethical manner, including the handling of actual or apparent conflicts of interest between personal and professional relationships. The Bank expects its Principal Officers to use good judgment and high ethical standards and to refrain from any form of illegal, dishonest or unethical conduct. Additionally, Principal Officers may not personally, or cause anyone else to, influence, coerce, manipulate or mislead any accountant engaged in preparing an audit for the Bank.
   2. Full, Fair and Timely Disclosure. It is the policy of the Bank that Principal Officers provide to shareholders and financial markets fair, accurate, timely and understandable disclosure in reports and documents that the Bank files with, or submits to the Securities Exchange Commission and other public communications, if applicable. The Bank realizes that only through such full, fair and timely disclosure can shareholders truly analyze the credibility of the Bank.
   3. Compliance with Applicable Governmental Laws and Regulations. Principal Officers must fully comply with the spirit and intent of all applicable laws, regulations and corporate governance standards.
   4. Internal Reporting of Code Violations. The Bank is committed to establishing procedures that will permit the receipt, retention and treatment of complaints received by the Bank regarding accounting, internal accounting controls or accounting matters. The Principal Officers will proactively promote ethical behavior, compliance with this Code of Ethics and compliance with the Code of Conduct. The Bank encourages Principal Officers and employees to talk to supervisors, managers, or other appropriate personnel when in doubt about the best course of action in a particular situation. Additionally, Principal Officers and other employees should report violations of laws; rules, regulations or codes of business conduct to Mr. Paul Grinberg, Audit Committee Chairman. Call him at 760-942-8885, email him at paul@grinberg.info or write him at PO Box 231243, Encinitas, CA. 92023-1243. The Bank will not permit retaliation against any employee for reports of breaches of the Code of Ethics or the Code of Conduct made in good faith.
   5. Administration of the Code of Ethics. It is the responsibility of each Principal Officer to be familiar with the Bank's Code of Ethics and the Code of Conduct. The Audit Committee is expected to make every reasonable effort to ensure that the Principal Officers comply with the provisions of the Code of Ethics.

      Principal Officers who violate provisions of the Code of Ethics may be subject to discipline, up to and including, but not limited to, dismissal from employment.

3. DISCLOSURES
   1. Disclosure of Code of Ethics. If the Bank is an OTS reporting company, the Bank is required to make a copy of its Code of Ethics publicly available. The Bank may accomplish this by filing its Code on its Internet site.
   2. Waivers. Any waiver from this Code may be made only with the prior consent of the Chairperson of the Board of Directors or a board committee appointed by the Chairperson. Any material waiver must be promptly disclosed to shareholders on the Bank's website.